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children for the years in issue. We recognize that it is
reasonable to infer Ms. Smith may have contributed a modicum
amount to the support of her children. However, Ms. Smith was
employed during some months of the years in issue, and, without
evidence of her income or additional assistance she may have
received from her mother, we are unable to determine the total
support available to the children by all able parties. Neither
Ms. Smith nor her mother testified at trial.
By failing to establish the total amount of support provided
to petitioner’s children from all sources, including Ms. Smith’s
public assistance, we are unable to conclude that petitioner
provided more than one-half of the children’s total support
during the years in issue. Therefore, we hold that petitioner is
not entitled to section 151 dependency exemption deductions for
the 1995, 1996, and 1997 tax years. Respondent is sustained on
this issue.
Head of Household Status
According to the relevant part of section 2(b), an
individual shall be considered a head of household if such
individual (1) is not married at the close of the taxable year
and (2) maintains as his home a household which constitutes for
more than one-half of the taxable year the principal place of
abode for a son or daughter.
Petitioner was not married to Ms. Smith at the close of
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